U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

RECEIVED 

MAY -5 2014 

HEARING DOCKET 

vs. 

Docket No. FAA-2013-0288 

FAA Case No. 2012SOI90209 

AVIONICS MASTERS, INC., 

Respondent. Judge Sullivan 

AMENDED COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.P.R. 13.208), and states as follows: 1 

I. 

I. On May 14, 2013, Respondent, Avionics Masters, Inc. was advised through a 

Final Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the 

amount of$7,150. On May 27,2013, the Agency Attorney received a written request for a 

hearing from the Respondent. 

II. 

2. At all times material herein, Avionics Masters was and is now the holder of Air 

Agency Certificate No. VIMR095K. 

3. Avionics Masters, Inc. is authorized to perform maintenance on Radio, Limited 

Airfame and Limited Instruments, as defined by the Operation Specifications and the Accepted 

Capability List. 

4. On or about December 22,2011, Avionics Masters approved for returned to 

service a Bendix/King directional gyro, model KG102A, serial number X32301. 

5. Avionics Masters was not authorized by its Operations Specifications or its 

Accepted Capability list to perform maintenance, including repairs, on the directional gyro. 

1 Additions to the Amended Complaint, as compared to the original Complaint, are marked with italics. Deletions 

from the original Complaint are marked with strike thre~~gl!. 
III. 

6. By reason of the feregeing facts and circumstances described in paragraphs 2-5 

of this Complaint, Respondent violated the following sections of the Federal Aviation 

Regulations: 

a. Section 145.5(a) in that no person may operate as a certificated repair 

station without, or in violation of, a repair station certificate, ratings, or operations specifications 

issued under this part; and 

b. Section 145.201(b) in that a certified repair station may not maintain or 

alter any article for which it is not rated, and may not maintain or alter any article for which it is 

rated if it requires special technical data, equipment, or facilities that are not available to it. 

7. Pursuant to 49 U.S.C. Sections 4630l(a)-(d), Respondent is subject to a civil 

penalty not to exceed $11,000 for each of the violations alleged. 

8. Under these facts and circumstances efthls ease, a civil penalty of $7,150 is 

appropriate. 

IV. 

9. Regardless of whether or not Respondent actually performed a repair of the 

Bendix/King directional gyro, model KG102A, serial number X32301, Respondent executed an 

FAA Form 8130-3 approving the gyro for return to service as repaired and describing the work 

as a repair. 

10. In the event that no repairs were performed on the directional gyro, Respondent 

falsely certified on the Form 8130-3 that repairs had been performed. 

11. In the event that no repairs were performed on the gyro, Respondent did not make 

an accurate description of the work performed on the directional gyro. 

v. 

12. In the alternative to the allegations in part Ill of the Complaint, by reason of the 

facts and circumstances described in paragraphs 9-11 of this Complaint, Respondent violated 

the following sections of the Federal Aviation Regulations: 

a. Section 43.9(a)(J) in that ,except as provided in paragraphs (b) and (c) of 

this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an 

aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry 

in the maintenance record of that equipment containing the following information: a description 

(or reference to data acceptable to the Administrator) of work performed; 
b. Section 43.5(a) in that no person may approve for return to service any 

aircraft, airframe, aircraft engine, propeller, or appliance, that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless the maintenance record entry required 

by 43.9 or 43.11, as appropriate, has been made. 

7. Pursuant to 49 US. C. Sections 46301(a)-(d), Respondent is subject to a civil 

penalty not to exceed $11,000for each of the violations alleged. 

8. Under these facts and circumstances, a civil penalty of $4,042 is appropriate. 

WHEREFORE, the Agency, by counsel respectfully requests that the Administrative Law 

Judge enter an order that Respondent be assessed a civil penalty in the amount of $7,150, as a 

result of Respondent's violations of§§ 145.5(a) and 145.201 (b). Alternatively, the Agency, by 

counsel respectfully requests that the Administrative Law Judge enter an order that Respondent 

be assessed a civil penalty in the amount of$4,042, as a result of Respondent's violations of 

§§ 43.9(a)(1) and 43.5(a). 

Attorney 

Office of the Regional Counsel 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Amended Complaint has been sent this date by the 

following methods: 

original and one copy via certified mail: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Attention:Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

Washington, D.C. 20591 

one copy via certified mail: 

Mohammad Ahmed Faruqui, Esq. 

Trial Lawyers Building 

633 SE 3rd Avenue, Suite 4R 

Ft. Lauderdale, FL 33301 

Honorable Judge J.E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. (Ell-310) 

Washington, DC 20590 

Date